Home Base Impairment Company, Inc. (a company also doing business
as RC21X) ("HBIC" or "we" or our) knows that your privacy is very important to you; and as such, we are
committed to providing you with a safe and secure user experience. This Privacy
Policy ("Policy") applies to your use of our mobile-based brain performance
monitoring application currently being marketed as the "Roberto App", as well
as to your use of the Roberto
App website(the "Roberto Site"). The
Roberto App is available on iOS and Android platforms and can be found on the
application stores for these platforms (e.g., Google Play, iTunes, the
Apple Store, etc.), as well as on the Roberto Site. This Policy describes how we collect,
use, secure, and share information of those individuals (collectively "you") who
access and/or use the Roberto App and the Roberto Site. This Policy also
describes how to access, update, and correct your personal information, as well
as the choices available to you regarding the same. If for any reason you do not
agree to the terms of this Policy, you must not use, and/or immediately stop
using, the Roberto App and the Roberto Site.

1.Information We Receive From Your Access and/or Use
of the Roberto Site and the Roberto App

In order to be able to use the Roberto App, you will need to register by
either using your email or your social media (e.g., Facebook) account.
If you register by using your email, in addition to providing that particular information,
you will also need to provide at least the following: your name, date of birth,
and a password. If, however, you register by using your social media account, we
will use that service to authenticate you. We may also receive other
information that you have agreed may be provided by that particular social
media account (e.g., your username, name, e-mail address, date of birth,
gender, etc.). We receive and collect this information so that it can be
used for the purposes explained in this Policy.

In addition to the information you provide to us during registration,
when you use the Roberto App or the Roberto Site, you may automatically submit
information about your computer, mobile device, or other devices used to access
the same and/or about how they are being used. We would do this to improve the
services and marketing we offer you.

From time to time, we may use push notifications in our mobile
applications to send you messages about your account, our company, other
products or services offered by our company, and/or add-ons to the Roberto App.
If such notifications are offered, you will also be offered with the
opportunity to opt out from receiving them.

oOur Use of Cookies. Like many other
companies, we and third parties that we work with may use cookies and other web
and mobile tracking technologies. We would use these technologies for
authentication, to store your preferences or progress, for analytics, and/or to
help us advertise our company and/or the products and services that we offer.
We may receive reports based on the use of these technologies by these
companies on an individual as well as aggregated basis. We would also use
cookies for authentication and preserving settings on the Roberto App as well
as across your visit to the Roberto Site. You can control the use of cookies at
the browser level. If you reject cookies, while you may still use the Roberto
App and the Roberto Site, your ability to use some features may be limited.

oMobile Analytics. We use mobile analytics
tools to better understand the functionality of our Roberto App. These tools
may record information about your usage, including how often you use it, the
events that occur within the application, and from where the application was
downloaded. We may also link the information recorded in analytics software to
personal information you submit to us.

2.How We Use Your Personal Information

We use your
information to improve the look and operation of the Roberto Site and/or the
Roberto App. This includes, but is not limited to, the following:

oAuthenticating
your login

oPersonalizing
your experience

oAllowing
you to monitor your performance and progress in the Roberto App

oCustomizing
and delivering information about our products and services by email

oProviding
customer support and sending confirmations about your account(s)

oProtecting
our intellectual property or other rights

oManaging
and improving our business, our websites, and our products

oProcessing
payments, if any.

You can opt
out of receiving marketing emails by navigating to your Email Notifications
page or by following the unsubscribe instructions included in each email.
Please note you may not opt out of certain transactional emails, such as when
we email you to confirm transactions, address account issues, or communicate
about customer support.

From time
to time, we may provide you the opportunity to participate in contests or
surveys, and accessing those opportunities may require that you provide additional
personal information or other demographic information. Please note that your participation
in these surveys or contests is completely voluntary; and you may decline to
provide such information.

We also
reserve the right to use non-personal information (e.g., de-identified
or aggregate data) for any purpose. For example, we may choose to show
aggregate performance measures to users to allow them to evaluate their
performance against other Roberto App users. Also, we may choose to disclose non-personal
performance statistics to university/research collaborators to evaluate, study,
and improve the effectiveness of our Roberto App. In these situations, all data
that will be disclosed to such third parties will either be provided in an aggregate
form, or in a form where all information that can be used to personally identify
has been removed. In addition, when we work with such third parties, we will contractually
prohibit them from attempting to re-identify individuals from data that has
been de-identified.

3.Minor's Privacy

We believe
that protecting the privacy of minor children under the age of 18 - or under
the age of majority in their jurisdiction of residence (collectively "Minors")
is extremely important. Although the Roberto Site and the Roberto App may be
used by Minors, including by a child under the age of thirteen, neither the
Roberto Site nor the Roberto App are designed to attract such Minors,
especially those under the age of thirteen. It is our intent and directive to
comply with all laws pertaining to the protection of a Minor's privacy,
including, without limitation, the Children's Online Privacy Protection Rule
(16 CFR 312). Regarding the privacy of all Minors who access the Roberto Site
and/or who use the Roberto App, it is the responsibility of that Minor's parent
or guardian to consent to such access or use and/or to monitor how it is being
used and any results being generated.

4.No Disclosure of Your Personal Information to Third Parties for
Marketing Purposes

We believe
in protecting your privacy; and therefore, we will not provide your personal
information to third parties for their marketing purposes.

5.When We Share Your Personal Information with Third Parties

If we
choose to share your personal information with third parties, we will only do
so in the following ways and with the following safeguards:

oService
Providers and Agents. We may share limited personal
information with certain third parties selected by us to help support our
operations. These include, for example, services that help us process payments,
analyze web traffic, send emails, and track customer support requests. In
addition, we may also share limited personal information to third parties that
help us market or advertise our company and our products and services. These
third parties may have access to some of your information only for purposes of
performing these tasks on our behalf; and we will contractually require them to
protect your information consistent with this Policy.

oAffiliates. We may
share limited personal information with our corporate affiliates, such as
entities under common ownership or control.

oBusiness Transfers. We may sell,
transfer, or otherwise share some or all of our assets in connection with a
merger, reorganization, business transaction, or in the event of bankruptcy. In
such scenarios, your information may be one of the assets transferred. We will
post a notice or otherwise notify you and collect your consent, as may be
required by law, before the information is transferred and becomes subject to a
different privacy policy.

oCompliance with
the Law and with Law Enforcement Requests and the Protection of Our Rights. We may
disclose your information when we have a good faith belief we are required to
do so by law, or in response to a subpoena, court order, or other legal
mechanism. We may also disclose your information when we have a good faith
belief that disclosure may prevent fraud and abuse of our company and/or our
company's products or services protect our property rights and/or the rights of
other individuals who use the Roberto App or the Roberto Site.

oConsent. We may
disclose your information when we believe we have your consent to do so, such
as when you contact customer support and ask us about your account, or when we
have the consent of someone we believe is authorized to consent on behalf of
you, such as the individual associated with the payment method for your
account. If you have expressly agreed to participate in a research study with
us or with a third party that incorporates your personal information collected
by HBIC from the Roberto Site or the Roberto App, we also may disclose your
information for the purpose of facilitating the research to which you have
consented.

6.Accessing, Reviewing, and Deleting Your Information

You may
access, review, correct, and/or delete your registration information through
your account page on the Roberto App. You may also access and/or delete the
personal information we have collected about you by contacting us at the
contact information listed below and requesting the same. While we will make
reasonable efforts to accommodate your requests, we reserve the right to impose
certain requirements and restrictions on such requests, such as limiting our
production of information to certain formats and not deleting information that
is no longer identifiable. We will retain your information for as long as your
account is active, or we think you may return as a user, or as necessary to
comply with our legal obligations, resolve disputes, and enforce our
agreements.

7.Security of Personal Information

We have
implemented and maintain reasonable security practices to protect against the
unauthorized access, use, modification, destruction, and/or disclosure of your
personal information. We follow generally accepted standards to protect the
personal information submitted to us, both during transmission and once we
receive it. However, no method of transmission or storage is completely secure;
and as such, we cannot guarantee absolute security.

8.Outside the United States Consent to Processing and Transfer of
Information

If you
access the Roberto App or the Roberto Site outside of the United States, you
fully understand and unambiguously consent to the transfer of your personal
information to, and the collection and processing of such personal information
in the United States.

9.Additional Information

oLinks to Third
Party Websites. The Roberto Site and the Roberto App may include links to other
sites that may collect personal information, and whose privacy practices may
differ from those set out in this Policy. If you have any concern or questions
regarding the privacy policies of these other sites, we encourage that you
review the privacy policies of those sites.

oSocial
Media Widgets. The Roberto Site and/or the Roberto App may also include social
media features (e.g., Facebook and Twitter buttons, etc.). Your
use of such features may result in the collection of your IP address and
information about the page you are visiting. This use may also set cookies on
your device to function properly. Your interactions with these features are
governed by the privacy policies of the company providing them.

10.Changes to
the Policy

We have the
right to update this Policy from time to time. If we make material changes
thereto, we will provide a notice to you by email, by posting a notification on
the Roberto Site and/or of the Roberto App, or by posting an updated privacy
policy on the Roberto Site at least 30 days in advance of its effective date.
Please note that, for existing users, unless otherwise provided by applicable
law, your continued use of the Roberto App and the Roberto Site following the
effective date of any Policy change means that you agree with, and consent to
be bound by, the updated Policy.

11.Contact
Information

We welcome
inquiries or comments about our Policy by emailing our Service
Center. You may also send a letter to the following address: